While most believe Washington, D.C., is a place riddled with inaction, sometimes things can change overnight.
The rally cry was simple and succinct: There will be no more delays for ICD-10. Only a month ago, CMS Administrator Marilyn Tavenner told attendees at the Healthcare Information and Management Systems Society's annual conference that there would be no delays in moving to the ICD-10-based coding system and that "now is not the time for us to stop moving forward."
All that forward momentum was thrown into turmoil Monday evening, when the Senate voted to approve a short-term solution to prevent cuts to physician payments that would have occurred under the much-maligned sustainable growth rate formula. Included in one section of the legislation is a delay in the adoption of ICD-10 code sets by HHS until at least Oct. 1, 2015.
The provision (and the wording leaves open the possibility of an extension beyond that) codifies a one-year delay in what had been expected to be an Oct. 1, 2014, start date for use of the code sets. That's on top of a one-year delay that HHS announced in August 2012, giving the industry a reprieve until this year.
The College of Healthcare Information Management Executives, as a member of the ICD-10 Coalition, has been vocal in pushing for adherence to the October 2014 start date for use of ICD-10 code sets. Members of the coalition -- representing a wide range of professional associations, insurers and solution vendors -- voiced disappointment on Tuesday about the delay and its inclusion in SGR legislation, which caught many by surprise.
Coalition members fully understand that the health care industry is not at this moment ready to move to using ICD-10 code sets. Segments of the industry lag behind in transition efforts. CHIME leadership has heard from some of its own members, indicating that they have much to do before they are ready to transition to ICD-10.
That said, the recent congressional action hurts transition efforts and undermines CMS' jurisdictional authority on several levels.
Making a transition to the expansive ICD-10 codes is a massive undertaking, with impacts far beyond upgrading versions of coding software. Because coding affects billing, ICD-10 will touch every aspect of a health care organization. Indeed, the ICD-10 transition typically affects dozens of computer systems used in most hospitals.
This technical transition involves far more than just the IT staff. Coding staff have much to learn about ICD-10, and many organizations have been working on training coders for months. Because ICD-10 enables a higher level of specificity, clinicians have to be trained and encouraged to provide more clinical detail to enable coders to select the correct ICD-10 codes. Much of that educational preparation now is at risk of being lost.
Managing this change at health care organizations requires substantial investment, beginning with IT department time and staff education. Estimates suggest that a one-year delay in implementing ICD-10 could cost between $1 billion and $6.6 billion. These expenses, borne by providers as operating costs, are not likely to be reimbursed.
Beyond the dollar cost, there is also a loss of momentum and energy around something that really is important. As the nation looks to reform the health care system to better manage population health and increase the cost-effectiveness of health care delivery, the ICD-10 delay pushes back the data support for needed improvements by at least another year.
"We're ready for this data to be used appropriately by the right constituencies, including our research and academic institutions," said Russell Branzell, CHIME's CEO. "Further delay or deviation from the October 2014 compliance date is disruptive and costly for health care delivery innovation, payment reform, public health and health care spending."
Do we need a national ICD-10 implementation plan that goes beyond setting an arbitrary go-live date, which is suddenly changed by legislation as a political-chip inclusion? Absolutely. There needs to be an overarching approach that creates target dates that can be achieved by the vast majority of providers, that doesn't threaten provider payments, that builds synergy between the efforts of government, providers, payers, vendors, and IT and coding professionals. Coordination should be the goal, not haphazard action. A successful transition to ICD-10 also will need assurances that payers and the government are ready for these more complex exchanges of data, and so cooperative testing needs to be successfully completed.
Of the many things the industry needs in this transitional time is appreciation for the time, effort and scope of change that's being requested. It's not just change for change sake, but change for the greater good of continuing the evolution of the nation's health care system.
That's why CHIME continues to believe the intent of federal health IT policy should be to raise all boats in this digital sea and to get the most return possible for the investment the nation's making in electronic systems. That means appreciating and accommodating the human component of this sea change in health care delivery.
The enemy of coordination is the feeling that the sands are continually shifting in the midst of massive change initiatives. No deadline date seems secure when that happens, as one of our members suggested in an email to us after the Senate vote.
"The door is open to push [the ICD-10 date] even further, which I strongly believe will occur," said the member, a long-time veteran CIO. "The scenario I predict is that a further push will be made on several fronts to now wait until ICD-11, and once that gains momentum, the naysayers will say that it 'isn't quite ready' and further delays will occur. My bet is that ICD-11 goes live shortly after 2020."
Health care IT – and the health care industry itself – needs more certainty than that.